McInnis v. A.M.F., Inc.

United States Court of Appeals for the First Circuit · 1985 · Evidence

765 F.2d 240 (1st Cir. 1985)

Updated August 22, 2026

EvidenceRule 408Rule 403diversity jurisdictionsettlement evidencethird-party settlementcausationinvalidity of claim

Facts

Plaintiff was riding a Harley-Davidson motorcycle when a car driven by Florence Poirier turned left and struck the motorcycle. Plaintiff claimed her leg was almost severed when the motorcycle later fell and its allegedly defective clutch housing shattered, while defendants argued the car impact itself caused the amputating injury. Before suing the motorcycle manufacturers, plaintiff settled with Poirier for $60,000 and executed a general release. At trial, the court admitted both evidence that plaintiff had consumed three beers before the accident and evidence of the Poirier release.

Issue

In a diversity products liability case, may the district court admit evidence of the plaintiff's settlement and release with a third-party tortfeasor as proof bearing on causation? Also, was evidence that plaintiff had consumed alcohol before the accident admissible under the applicable evidentiary standards?

Rule

In diversity cases, the Federal Rules of Evidence govern ordinary evidentiary admissibility questions unless the state rule is genuinely substantive rather than a procedural relevance rule. Under Rule 408, a settlement agreement with a third party is inadmissible when offered to prove liability, invalidity of the claim, or causation, because causation is an integral component of claim validity; such evidence may be admitted only for another legitimate purpose. Under Rule 403, relevant evidence such as alcohol consumption may be admitted unless its probative value is substantially outweighed by unfair prejudice, and appellate review is for abuse of discretion.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In a diversity action in federal court in Boston, Lena Ortiz sues Harborline Motors, alleging a defective seatback caused a spinal injury during a collision. Before filing suit, Lena settled with the other driver, Devon Pike, for the limits of his insurance policy. Harborline offers the settlement at trial to argue Devon, not the seatback, caused Lena's injury.

Should the federal court admit the settlement for that purpose?

Explanation. The majority held that Rule 408 applies to completed settlements with third parties when offered against a party to the present litigation. It also held that causation is an integral part of the validity or invalidity of a tort claim, so a settlement cannot be used to show someone else caused the injury. The settlement is therefore inadmissible for that purpose.